Guide to lead exposure in the construction industry

A Guide to
Lead Exposure in the
Construction Industry
Sydney Cheryl Sutton
Editor
N. C. Department of Labor
Division of Occupational Safety and Health
1101 Mail Service Center
Raleigh, NC 27699- 1101
Cherie K. Berry
Commissioner of Labor
Acknowledgments
A Guide to Lead Exposure in the Construction Industry is
based upon the U. S. Department of Labor’s Program
Highlights fact sheet series ( Fact Sheet No.’ s OSHA 93- 47
through 93- 52) concerning the topic of lead in construction,
combined with information from a U. S. OSHA booklet
titled Lead in Construction ( OSHA 3142). Additional mate-rial
was provided by North Carolina Department of Labor
Health Standards Officer J. Edgar Geddie, Ph. D., and
Health Compliance Supervisor Paul Sullivan.
This guide is intended to be consistent with all existing
OSHA standards; therefore, if an area is considered by
the reader to be inconsistent with a standard, then the
OSHA standard should be followed.
To obtain additional copies of this book, or if you have ques-tions
about N. C. occupational safety and health standards
or rules, please contact:
N. C. Department of Labor
Bureau of Education, Training and Technical Assistance
1101 Mail Service Center
Raleigh, NC 27699- 1101
Phone: ( 919) 807- 2875 or 1- 800- NC- LABOR
____________________
Additional sources of information are listed
on the inside back cover of this book.
____________________
The projected cost of the OSHNC program for federal fiscal year 2002– 2003 is $ 13,130,589.
Federal funding provides approximately 37 percent ($ 4,920,000) of this total.
Printed 12/ 97, 3M
N. C. Department of Labor
Occupational Safety and Health Program
Cherie K. Berry
Commissioner of Labor
OSHA State Plan Designee
Allen McNeely
Deputy Commissioner for Safety and Health
Kevin Beauregard
Assistant Deputy Commissioner for Safety and Health
Contents
Part Page
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iiv
1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11
2 Worker Protection Programs . . . . . . . . . . . . . . . . .14
3 Exposure Assessment . . . . . . . . . . . . . . . . . . . . . . . . .17
4 Engineering Controls . . . . . . . . . . . . . . . . . . . . . . . . . . 11
5 Housekeeping and Personal
Hygiene Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
6 Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
7 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . 23
8 Medical Assessment and Recordkeeping.... 28
iii
Foreword
Lead is a cumulative and toxic substance. People who
swallow or inhale lead compounds may become ill or die
from lead poisoning. Although lead is eliminated from
the body at a slow rate, inhaling even a small amount of
a lead compound over an extended period of time may
cause lead poisoning. Immediate symptoms of disease
may not be noticeable. As the blood is circulated
through the body, lead is stored in various organs and
body tissues. The lead stored in the body may be slowly
causing irreversible damage: first to the cells, then to
the organs, and finally to the whole body system.
Employers must be aware of workplace hazards fac-ing
their workers and must take appropriate action to
minimize or eliminate exposure to these hazards. A
Guide to Lead Exposure in the Construction Industry
discusses precautions that can prevent serious health
risks to workers due to exposure to lead compounds.
In this state, North Carolina Department of Labor
consultants and inspectors administer the federal
OSHA laws through a plan approved by the U. S.
Department of Labor. All current OSHA standards are
enforced. Many educational programs, publications
( including this guide), and other services are also
offered to help inform people about their rights and
responsibilities regarding OSHA.
As you look through this guide, please remember that
OSHA’s mission is greater than just enforcement. An
equally important goal is to help citizens find ways to
create safe and healthy workplaces. Reading and using
the information in this booklet, like other educational
materials produced by the North Carolina Department
of Labor, can help.
Cherie K. Berry
Commissioner of Labor
iv
1
Introduction
Health Hazards of Lead Exposure in
the Construction Industry
Pure lead ( Pb) is a heavy metal ( at room temperature
and pressure) and is a basic chemical element. It can
combine with various other substances to form numer-ous
lead compounds. When absorbed into the body in
certain doses lead is toxic. It can be absorbed into the
body by inhalation and ingestion. Except for certain
organic lead compounds not covered by OSHA’s interim
1926.62 standard, lead is not absorbed significantly
through the skin. When scattered through the air as a
dust, fume, or mist, lead can be inhaled and absorbed
through the lungs and upper respiratory tract.
Inhalation of airborne lead is generally the most impor-tant
source of occupational lead absorption. Lead also
can be absorbed through the digestive system if it
enters the mouth and is ingested.
A significant portion of the lead inhaled or ingested
gets into the blood stream. Once in the blood stream,
lead is circulated through the body and stored in various
organs and body tissues. Some of this lead is quickly
filtered out of the body and excreted, but some remains
in the blood and tissues. As exposure continues, the
amount stored will increase if the body is absorbing
more lead than it is excreting. The lead stored in the
tissues can slowly cause irreversible damage, first to
individual cells, then to organs and whole body systems.
1
Long- term ( chronic) overexposure to lead may result
in severe damage to the blood- forming, nervous,
urinary, and reproductive systems. Some common
symptoms include the following:
Damage to the central nervous system in general and
the brain in particular is one of the most severe forms of
lead poisoning. Chronic overexposure to lead also signif-icantly
impairs the reproductive systems of both men
and women. Lead can alter the structure of sperm cells,
raising the risk of birth defects, and there is evidence of
miscarriage and stillbirth in women exposed to lead or
whose husbands have been exposed to lead. Children
born of parents who were exposed to excess lead levels
are more likely to have birth defects, mental
retardation, behavioral disorders, or to die during the
first year of childhood.
The interim OSHA standard aims to reduce the expo-sure
to lead for construction workers. The most signifi-cant
way to achieve this is by lowering the permissible
exposure limit ( PEL) from 200 micrograms per cubic
meter of air ( 200 μg/ m3) as an 8- hour time weighted
average ( TWA) to 50 μg/ m3.
For the purpose of this standard, lead includes
metallic lead, all inorganic lead compounds, and organic
lead soaps. OSHA’s lead in construction standard
applies to all construction work where an employee may
be occupationally exposed to lead. All work related to
2
loss of appetite
constipation
excessive tiredness
headache
fine tremors
colic with severe
abdominal pain
metallic taste
nervous irritability
hyperactivity
muscle and joint pain
or soreness
weakness
anxiety
pallor
insomnia
numbness
dizziness
construction, alteration, or repair, including painting
and decorating, is included.
Engineering and Work Practice
Controls
The lead in construction standard requires employers
to use, when feasible, engineering and work practice
controls to reduce and maintain employee lead exposure
to or below the PEL. When all feasible controls have
been instituted but are not sufficient to reduce employ-ee
exposure to or below the PEL, they must be used to
reduce exposure to the lowest feasible level and supple-mented
by respirators.
Engineering controls reduce employee exposure in
the workplace either by removing or isolating the haz-ard
or isolating the worker from exposure through the
use of technology. Under the lead in construction stan-dard,
mechanical ventilation may be used to control
lead exposure. If used, the employer must evaluate, as
necessary, the mechanical performance of the system in
controlling exposure to maintain its effectiveness.
Work practice controls reduce the likelihood of
exposure by altering the manner in which a task is
performed. Safe work practices under the lead in con-struction
standard include, but are not limited to,
maintaining separate hygiene facilities ( i. e., change
rooms, showers, hand washing facilities, and lunch
areas) and requiring proper housekeeping practices
( i. e., cleanup methods).
3
2
Worker Protection Programs
Lead has been poisoning workers for thousands of
years. Traditionally, most over- exposures to lead in the
construction industry have been found in the trades,
such as plumbing, welding, and painting.
In building construction, lead is frequently used for
roofs, cornices, tank linings, and electrical conduits. In
plumbing, soft solder, used chiefly for soldering tinplate
and copper pipe joints, is an alloy of lead and tin. Soft sol-der,
in fact, has been banned for many uses in the United
States. The use of lead- based paint in residential applica-tion
has been banned by the Consumer Product Safety
Commission. However, since lead- based paint inhibits the
rusting and corrosion of iron and steel, it is still used on
bridges, railways, ships, lighthouses, and other steel
structures, although substitute coatings are available.
Significant lead exposures can also arise from remov-ing
paint from surfaces previously coated with lead-based
paint, such as in bridge repair, residential reno-vation,
and demolition. With the increase in highway
work, including bridge repair, residential lead
abatement, and residential remodeling, the potential for
exposure to lead- based paint has become more common.
The trades potentially exposed to lead include iron
work, demolition work, painting, lead- based paint
abatement work, plumbing, heating/ air- conditioning,
electrical work, and carpentry/ renovation/ remodeling.
Operations that generate lead dust and fumes
include the following:
✦ Flame- torch cutting, welding, the use of heat guns,
sanding, scraping and grinding of lead painted sur-faces
in repair, reconstruction, dismantling, and
demolition work.
4
✦ Abrasive blasting of bridges and other structures
containing lead- based paints.
✦ Use of torches and heat guns, and sanding, scrap-ing,
and grinding lead- based paint surfaces during
remodeling or abating lead- based paint.
✦ Maintaining process equipment or exhaust duct
work.
The employer of construction workers is responsible
for the development and implementation of a worker
protection program in accordance with 29 CFR 1926.20
and 29 CFR 1926.62. This program is essential in mini-mizing
worker risk of lead exposure. Construction pro-jects
vary in their scope and potential for exposing
workers to lead and other hazards. Many projects may
involve limited exposure, such as the removal of paint
from a few interior residential doors. Others may
involve the removal, or stripping off, of substantial
quantities of lead- based paints on large bridges. The
employer should, as needed, consult a qualified safety
and health professional 1 to develop and implement an
effective worker protection program.
The most effective way to protect workers is to mini-mize
exposure through the use of engineering controls
and good work practices. It is OSHA policy that respira-tors
are not to be used in lieu of engineering and work
practice controls to reduce employee exposures to or
below the PEL. Respirators can only be used in combi-nation
with engineering controls and work practices to
control employee exposures. OSHA’s interim final stan-dard
for lead in construction limits worker exposures to
50 micrograms of lead per cubic meter of air averaged
over an eight- hour workday.
5
________
1Sources for professional safety and health advice include insurance
carriers, trade organizations, state 7( c)( 1) on- site consultation programs,
and consultants.
At the minimum, the following elements should be
included in the employer’s worker protection program
for employees exposed to lead:
✦ Hazard determination, including exposure assess-ment,
( see Lead- Related Tasks Regarding Interim
Worker Exposure in Part 3, Table 1 in this guide)
✦ Engineering and work practice controls
✦ Respiratory protection
✦ Protective clothing and equipment
✦ Housekeeping
✦ Hygiene facilities and practices
✦ Medical surveillance and provisions for medical
removal
✦ Training
✦ Signs
✦ Recordkeeping
To implement the worker protection program properly,
the employer needs to designate a competent person ( one
who is capable of identifying existing and predictable
hazards or working conditions that are hazardous or
dangerous to employees, in accordance with the general
safety and health provisions of OSHA’s construction
standards). The competent person must have the autho-rization
to take prompt corrective measures to eliminate
such problems. Qualified medical personnel must be
available to advise the employer and employees on the
health effects of employee lead exposure and supervise
the medical surveillance program.
6
3
Exposure Assessment
Assessing Exposures
Where initial employee exposure is at or above the
action level ( 30 μg/ m3), the employer must collect per-sonal
samples representative of a full work shift,
including at least one sample for each shift or for the
shift with the highest exposure level for each job classi-fication
in each work area. These samples must repre-sent
the monitored employee’s regular daily exposure to
lead. Measurements made within the previous 12
months may be used to determine how far above the
action level employee exposure may be.
An initial determination of whether employees are
exposed to lead at or above the action level and the
results of that determination must be made available
based on the following:
• Any information, observation, or calculation that
indicates employee exposure to lead.
• Any previous measurements of airborne lead.
• Any employee complaints of symptoms attributable
to lead exposure.
• Objective data regarding materials, processes, or
operations.
The employer may discontinue required monitoring
when at least two consecutive measurements, taken at
least seven days apart, are below the action level.
Monitoring for the initial determination whether
employees are exposed at or above the action level may
be limited to a representative sample of those employees
exposed to the greatest concentrations of airborne lead.
7
Measurements made within the preceding 12 months,
which were performed by the same employer and applic-able
to the same employee tasks, may be used.
The employer must establish and maintain an accu-rate
record documenting the nature and relevancy of
previous exposure data. Instead of performing initial
monitoring, the employer may rely on objective data to
demonstrate that a particular lead- containing material
or product does not result in employee exposure at or
above the action level when in use, being processed, or
handled.
Until the employer performs an exposure assessment
and documents that employees are not exposed above
the PEL, the employer must treat employees who per-form
certain operations as if they were exposed above
the PEL. This means that the employer must provide
respiratory protection, protective work clothing and
equipment, change areas, hand washing facilities, bio-logical
monitoring, and training for employees perform-ing
these “ trigger” tasks. Table 1, in this section,
provides a list of the lead- related tasks that require
interim protection and a description of each of those
operations.
For an initial determination that indicates no
employee is exposed at or above the action level ( 30
��g/ m3), the employer must keep a written record of the
determination, including the date, location within the
work site, and the name and social security number of
each monitored employee.
Monitoring and Observing
If the initial determination proves employee exposure
is below the action level, further exposure determina-tion
need not be repeated unless there is a change in
processes or controls. If employee exposure is at or
above the action level, but at or below the PEL, the
8
employer must perform monitoring at least every six
months and continue until at least two consecutive
measurements, taken at least seven days apart, are
below the action level.
If employee exposure is above the PEL, the employer
must perform monitoring quarterly and continue until
at least two consecutive measurements, taken at least
seven days apart, are at or below the PEL but at or
above the action level. The employer then must repeat
and continue monitoring every six months to bring the
exposure to or below the action level as described above.
Whenever there is a change of equipment, process,
control, personnel, or a new task has been initiated that
could increase employee lead exposure at or above the
action level, the employer must conduct additional mon-itoring.
The employer must notify each employee in writing of
employee exposure assessment results within five work-ing
days after their receipt. Whenever the results indi-cate
that the representative employee exposure, with-out
the use of respirators, is at or above the PEL, the
employer must include a written notice stating that the
employee’s exposure was at or above that level and
describing the corrective action taken or to be taken to
reduce exposure below that level.
The employer must provide affected employees or
their designated representatives an opportunity to
observe any monitoring of employee lead exposure. This
includes providing and ensuring the use of respirators
and protective clothing and equipment whenever moni-toring
requires entry into an area where such is
required. The observer is entitled to an explanation
of the measurement procedures, to observe all steps
related to lead monitoring performed at the place of
exposure, and to record the results obtained or receive
copies of the results when returned by the laboratory.
9
Table 1
Lead- Related Tasks Requiring Interim Worker Protection
10
Abrasive blasting
Welding, cutting,
and burning on steel
structures
Lead burning
Manual scraping and
sanding
Manual demolition of
structure
Heat gun application
Using lead containing
mortar
Abrasive blasting
enclosure movement
and removal
Power tool cleaning
Rivet busting
Cleanup activities
where dry expendable
abrasives are used
Removal of scale, paint, and dirt from surfaces
prior to repainting; abrasive media includes sand,
steel grit, aluminum oxide, “ Black Beauty”
( processed boiler slag), and others.
Process of heating coated steel to its melt
temperature typically using an oxyacetylene
torch or arc welder.
Involves torch melting or fusing of lead or alloyed
lead to another lead object.
Associated with lead paint removal and involves
application of hand- held scraping or sanding tool to
the painted surface containing lead.
Involves removal of walls ( plaster, gypsum) or
building components coated with lead- based paint
that is subsequently scraped off.
Use of a heat gun that produces a stream of hot
air directed to surfaces to melt lead paint that is
subsequently scraped off.
Used in high pressure acid tanks lined with
specialized tile of lead brick held in place with
specialized lead- containing mortar or grout; these
tank linings periodically require repainting, repair-ing,
or relining involving lead containing mortar.
Movement and removal of blasting enclosure or
containment units as work proceeds on structures;
such units are often composed of flexible nylon,
plastic, or burlap tarpaulins upon which lead dust
will accumulate and be retained when movement
of the structure occurs.
Removal of rivets from steel structures where lead-containing
paints are present; rivet busting can
involve use of torches and mechanical means for
rivet extraction.
Use of power tools ( grinders, brushes, needle
guns, sanders, etc.) to remove dirt, scale, or paint
from structures where lead- based paint is present.
Use of non- recycled dry abrasives during abrasive
blasting operations on structures where lead-containing
paint is found.
4
Engineering Controls
Lead is a cumulative and persistent toxic substance.
Lead- caused health effects may result from low levels of
exposure over prolonged periods of time. Engineering
controls and good work practices must be used where
feasible to minimize employee exposure to lead. At a
minimum, exposures must not exceed the OSHA interim
final PEL of 50 micrograms per cubic meter of air ( 50
μg/ m3) averaged over an 8- hour period. When feasible
engineering controls and work practice controls cannot
reduce worker exposure to lead at or below 50 μg/ m3,
respirators must be used to supplement engineering and
work practice controls.
A competent person 2 should review all site operations
and stipulate the specific engineering controls and work
practices designed to reduce worker exposure to lead.
Engineering measures include local and general exhaust
ventilation, process and equipment modification, materi-al
substitution, component replacement, and isolation
or automation. Examples of recommended engineering
controls that can be used to reduce worker exposure to
lead are as follows:
Exhaust Ventilation
Power tools used for the removal of lead- based paint
should be equipped with dust collection shrouds or
other attachments exhausted through a high- efficiency
particulate air ( HEPA) vacuum system. Operations
such as welding, cutting/ burning, or heating should be
11
________
2One who is capable of identifying existing and predictable lead hazards in
the surroundings or working conditions and who has authorization to take
prompt corrective measures to eliminate them.
provided with local exhaust ventilation. HEPA vacuums
should be used during cleanup activities.
For abrasive blasting operations where full contain-ment
exists or is required, the containment structure
should be designed to optimize the flow of ventilation
air past the worker( s), so that the airborne concentra-tion
of lead is reduced and the visibility is increased.
The affected area should be maintained under negative
pressure to reduce the chances that lead dust will cont-aminate
areas outside the enclosure. A containment
structure should be equipped with dust collection and
an air- cleaning device to control emissions of
particulate matter to the environment.
Enclosure/ Encapsulation
Lead- based paint can be made inaccessible either by
encapsulating it with a material that bonds to the sur-face,
such as acrylic or epoxy coating or flexible wall cov-erings,
or by enclosing it using systems such as gypsum
wallboard, plywood paneling, and aluminum, vinyl or
wood exterior siding. Floors coated with lead- based
paint can be covered using vinyl tile or linoleum flooring.
The building owner, or other responsible person,
should oversee the custodial and maintenance staffs
and contractors with regard to all activities that involve
enclosed or encapsulated lead- based paint. This will
minimize potential inadvertent release of lead during
maintenance, renovation, or demolition.
Substitution
Zinc- containing primers covered by an epoxy interme-diate
coat and polyurethane topcoat are commonly used
instead of lead- containing coatings.
Mobile hydraulic shears can be substituted for torch
cutting under certain circumstances.
12
Surface preparation equipment, such as needle guns
with multiple reciprocating needles completely enclosed
within an adjustable shroud, can be substituted for
abrasive blasting under certain operations. The shroud
captures dust and debris at the cutting edge and can be
equipped with a HEPA vacuum filtration system with a
self- drumming feature. One such commercial unit can
remove lead- based paint from flat steel and concrete
surfaces, outside edges, inside corners, and pipes.
Chemical strippers, used primarily on the exterior of
buildings, surfaces involving carvings or molding, or
intricate iron works, can be used in place of hand scrap-ing
using a heat gun. Chemical removal generates less
airborne lead dust; however, these strippers can be haz-ardous.
The material safety data sheets ( MSDSs) for
the products used must be reviewed by the employer for
information on worker exposure hazards from the
chemical ingredients and protective measures
recommended by the manufacturer.
Component Replacement
Lead- base painted building components ( i. e.,
windows, doors, and trim) can be replaced either with
new components free of lead- containing paint or with
the same components after the paint has been removed
off- site. Replacement is a permanent solution.
Process/ Equipment Modification
Brush/ roller application of lead paints or other lead-containing
coatings is a safer method than spraying.
This method of application introduces little or no paint
mist into the air where the mist can present a lead
inhalation hazard. ( Note: There is a ban on the use of
lead- based paint in residential housing.)
Non- silica containing abrasive ( e. g., steel or iron
shot/ grit) should be used, where practical, instead of
13
sand in abrasive blasting operations. When sand is
used, the free silica portion of the dust presents a signif-icant
respiratory health hazard.
Blasting techniques that are less dusty than abrasive
blasting and that can be effective under some conditions
include: ( 1) hydro- or wet- blasting ( using high- pressure
water with or without abrasive, or surrounding the
blast nozzle with a ring of water) and ( 2) vacuum blast-ing
where a vacuum hood for material removal is posi-tioned
around the exterior of the blasting nozzle.
Heat guns used to remove lead- based paints in resi-dential
housing units should be of the flameless electri-cal
softener type. Heat guns should have electronically
controlled temperature settings to allow usage below
700 degrees F. Heat guns should be equipped with vari-ous
nozzles to cover all common applications and to
limit the heated work area.
When using abrasive blasting with vacuum hood on
exterior building surfaces, care should be taken that the
configuration of the heads on the blasting nozzle match
the configuration of the substrate, so that the vacuum is
effective in containing debris.
Since HEPA vacuum cleaners can be used to clean
surfaces other than just floors, operators should have
attachments appropriate for use on unusual surfaces.
The proper use of brushes of various sizes and crevice
and angular tools, when needed, will enhance the quality
of the HEPA- vacuuming process and help reduce the
amount of lead dust released into the air.
Isolation
Although it is not feasible to completely enclose
and ventilate some abrasive blasting operations, it
is possible to isolate many operations to help reduce
the potential for exposure to lead. Isolation, in this
instance, consists of keeping employees not involved
14
in the blasting operations as far away as possible from
the work area. By placing the employees a greater dis-tance
from the source of lead exposure, their exposures
will be reduced.
15
5
Housekeeping and Personal
Hygiene Practices
Lead is a cumulative and persistent toxic substance
that poses a serious health risk. A rigorous housekeep-ing
program and adherence to basic personal hygiene
practices will minimize employee exposure to lead. In
addition, these two elements of the worker protection
program will help to prevent taking lead- contaminated
dust out of the worksite and home to the workers’ fami-lies,
thus ensuring that the duration of lead exposure
does not extend beyond the workshift and providing
added protection to employees and their families.
Housekeeping
An effective housekeeping program involves at least
daily removal of accumulations of lead dust and lead-containing
debris. Vacuuming lead dust with high-efficiency
particulate air ( HEPA) filtered equipment
or wetting it with water before sweeping are effective
control measures. Such cleaning operations should be
conducted, whenever possible, at the end of the day,
after normal operations cease. Furthermore, all
persons doing the cleanup should be provided with
suitable respiratory protection and personal protective
clothing to prevent contact with lead.
In addition, all lead- containing debris and contami-nated
items accumulated for disposal should be collected
and put into sealed impermeable bags or other closed
impermeable containers. Bags and containers should
be appropriately labeled as lead- containing waste.
These measures are especially important as they mini-mize
additional sources of exposure that engineering
16
controls generally are not designed to control. Disposal
of lead- containing waste should be done in accordance
with federal, state, and local government regulations.
Personal Hygiene Practices
To minimize exposure to lead, special attention should
be given to workers’ personal hygiene. The employer
must provide and ensure that workers use washing
facilities. Clean change areas and separate noncontami-nated
eating areas must also be provided. Cars should
be parked where they will not be contaminated with
lead. These measures will reduce the worker’s period of
exposure to lead and the ingestion of lead, ensure that
the duration of lead exposure does not extend beyond
the workshift, significantly reduce the movement of lead
from the worksite, and provide added protection to
employees and their families.
Change areas: The employer must provide a clean
change area for employees exposed above the permissi-ble
exposure limit or who are performing certain “ trig-ger”
tasks. ( See Table 1 in Part 3 of this guide.) The
change area must be equipped with storage facilities for
street clothes and a separate area with facilities for the
removal and storage of lead- contaminated protective
work clothing and equipment. This separation is essen-tial
in preventing cross contamination of the employee’s
clothing.
Clean change areas are to be used for taking off
street clothes, suiting up in clean working clothes ( pro-tective
clothing), donning respirators prior to beginning
work, and dressing in street clothes after work. No lead-contaminated
items should enter this area.
Work clothing must not be worn away from the job
site. Under no circumstances should lead- contaminated
work clothes be laundered at home or taken from the
17
worksite, except to be laundered professionally or prop-erly
disposed of following applicable federal, state, and
local regulations.
Showers: When there is potential for extensive conta-mination
of the employees’ skin, hair, and protective
clothing, shower facilities must be provided, if feasible,
so that exposed employees can wash lead from their
skin and hair prior to leaving the worksite. Where
showers are provided, employees must change out of
their work clothes and shower before changing into
their street clothes and leaving the worksite.
Workers who do not change into clean clothing before
leaving the worksite may contaminate their homes and
automobiles with lead dust. Other members of the
household may then be exposed to harmful amounts of
lead.
Personal practices ( eating, drinking, etc.): The
employer must ensure that employees who work with
lead either clean or remove their protective clothing and
wash their hands and face prior to eating, drinking,
smoking, or applying cosmetics. These latter practices
are never permitted while in the work area or in areas
subject to the accumulation of lead. HEPA vacuuming
can be used to remove loose contamination from the
work clothing prior to eating.
Washing facilities: Adequate washing facilities must
be provided for employees. Such facilities must be in
near proximity to the worksite and provided with water,
soap, and clean towels to enable employees to remove
lead contamination from their skin.
Contaminated water from washing facilities and
showers must be disposed of in accordance with applica-ble
local, state, or federal regulations.
End- of- day procedures: Workers who are exposed to
lead should follow these procedures upon finishing work
for the day:
18
✦ Place disposable coveralls and shoe covers into
containers designated for lead waste.
✦ Place lead- contaminated clothes, including
work shoes, and personal protective equipment for
laundering/ cleaning ( by the employer) in a closed
container.
✦ Take a shower and wash hair.
✦ Change into street clothes.
19
6
Protective Clothing
At no cost to employees, employers must provide
workers who are exposed to lead above the PEL and for
whom the possibility of skin contamination or skin or
eye irritation exists, clean, dry protective work clothing
and equipment. Appropriate changing facilities must
also be provided. Appropriate protective work clothing
and equipment used on construction sites can include:
• Coveralls or other full- body work clothing
• Gloves
• Vented goggles or face shields with protective
spectacles or goggles
• Welding or blasting helmets, when required
Disposable coveralls and separate shoe covers may be
used, if appropriate, to avoid the need for laundering.
Nondisposable coveralls must be replaced daily. If an
employee leaves the work area wearing protective cloth-ing,
the clothing should be cleaned with high- efficiency
particulate air ( HEPA) filter vacuum equipment to
remove loose particle contamination; or as an alterna-tive,
the coveralls should be removed. Before respirators
are removed, HEPA vacuuming or other suitable method,
such as damp wiping, shall be used to remove loose
particle contamination on the respirator and at the
face- mask seal. Use work garments of appropriate size,
and use duct tape to reinforce their seams ( e. g., under-arm,
crotch, and back).
Contaminated clothing that is to be cleaned, laundered,
or disposed of must be placed in closed containers.
Containers must be labeled with the following warning:
20
Persons responsible for handling contaminated cloth-ing
must be informed of the potential hazard in writing.
At no time should lead be removed from protective cloth-ing
or equipment by any means that disperses lead into
the work area, such as brushing, shaking, or blowing.
At no time should workers be allowed to leave the
worksite wearing lead- contaminated clothing or equip-ment,
( e. g., shoes, coveralls, or head gear). All contami-nated
clothing and equipment must be prevented from
reaching the worker’s home or vehicle. This is an
essential step in reducing the movement of lead
contamination from the workplace into a worker’s
home and provides added protection to employees and
their families.
Gloves and protective clothing should be appropriate
for the specific chemical exposure ( e. g., solvents and
caustics). Cotton gloves provide some protection against
the contamination of hands and cuticles with lead dust.
Workers should wear clothing that is appropriate for
existing weather and temperature conditions under the
protective clothing.
Heat Stress
Workers wearing protective clothing can face a risk
from heat stress. Additionally, heat stress may be an
important concern when working in a hot environment
or within containment structures. Heat stress is caused
by a number of interacting factors, including: environ-mental
conditions, type of protective clothing worn, the
work activity required, and the individual characteris-tics
of the employee.
21
CAUTION: Clothing contaminated with
lead. Do not remove dust by blowing or
shaking. Dispose of lead- contaminated
wash water in accordance with applic-able
local, state, or federal regulations.
In situations where heat stress is a concern,
employers should use appropriate work/ rest regimens
and provide heat stress monitoring that includes
measuring employees’ heart rates, body temperatures,
and weight loss.
A source of water or electrolytic drink should be close
to the work area ( in a noncontaminated eating/ drinking
area) so that it will be used often. Workers should wash
their hands and face prior to drinking any fluid.
Frequent fluid intake throughout the day will replace
body fluids lost to evaporation. If such measures are
used to control heat stress, protective clothing can be
safely worn to provide the needed protection against
lead exposure. The possibility of heat stress and its signs
and symptoms should be discussed with all workers.
22
7
Respiratory Protection
Although engineering and work practice controls are
the primary means of protecting workers, source control
at construction sites is often not sufficient to control
exposure, and airborne lead concentrations may be high
or vary widely. In the construction industry, respirators
must be used at times to supplement engineering
controls and work practices whenever these controls are
technologically incapable of reducing worker exposures
to lead to 50 μg/ m3 or below.
To provide adequate respiratory protection, respira-tors
must be donned before entering the work area and
should not be removed until the worker has left the
area, or as part of a decontamination procedure.
Respiratory Protection Program
When respirators are provided, the employer must
establish a respiratory protection program in
accordance with the OSHA standards on lead in
construction ( interim) respirator protection, 29 CFR
1926.62( f)( 4) and 29 CFR 1910.134. Minimum require-ments
for an acceptable respirator program for lead
include the following elements:
✦ Written standard operating procedures governing
the selection and use of respirators.
✦ Selection of respirators on the basis of hazards to
which the worker is exposed.
✦ Instruction and training in the proper use of respi-rators
and their limitations.
✦ Regular inspection and cleaning, maintenance,
and disinfection. ( Worn or deteriorated parts must
be replaced, including replacement of the filter
23
element in an air- purifying respirator whenever an
increase in breathing resistance is detected.)
✦ Storage in a convenient, clean, and sanitary loca-tion
with protection against sunlight and physical
damage.
✦ Appropriate surveillance of work area conditions
and degree of worker exposure or stress ( physiolog-ical
or psychological) must be maintained.
✦ Evaluation to determine the continued
effectiveness of the program.
✦ Physician’s determination that the employee is
physically able to perform the work and wear a
respirator while performing the work. ( Respirator
user’s medical capacity to wear and work with a
respirator should be reviewed annually.)
✦ Use of Mine Safety and Health Administration/
National Institute for Occupational Safety and
Health ( MSHA/ NIOSH) certified respirators.
✦ Fit testing of negative- pressure respirators.
✦ Breathing air used for supplied- air respirators
must meet the requirements prescribed in 29 CFR
1910.134( b), ( d), ( e), and ( f).
✦ Standing permission for employees to leave the
work area to wash their faces and respirator face
pieces whenever necessary to prevent skin irrita-tion
associated with respirator use.
Respirator Selection
Lead concentrations may vary substantially through-out
a work shift as well as from day to day. The highest
anticipated work concentration is to be used in the initial
selection of an appropriate respirator. The employer
must provide respiratory protection, at no cost to the
employee, and must ensure its proper use in the follow-ing
circumstances:
24
✦ During the time period necessary to install and
implement engineering or work practice controls.
✦ Engineering and work practice controls that can be
instituted are not sufficient to reduce employee
exposure to or below the permissible exposure
limit ( PEL).
✦ Whenever an employee requests a respirator.
An appropriate respirator, which has been approved
by the Mine Safety and Health Administration ( MSHA)
and NIOSH, must be selected to protect against lead
dust, fumes, and mists. ( See Table 2, in this section, for
recommended respiratory protection.)
Respirators issued to employees must exhibit mini-mum
facepiece leakage and fit the employee properly.
Employers must perform either quantitative or qualita-tive
( for half- mask respirators only) face fit tests at the
time of initial fitting and at least every six months for
each employee wearing a negative- pressure respirator.
If the employee shows signs of breathing difficulty dur-ing
the fit test or during use, the employer must make
an examination available in accordance with the med-ical
surveillance requirements of the standard.
Employees who use filter respirators must be permit-ted
to change the filter elements whenever an increase
in breathing resistance is detected. They must be
allowed to leave work areas to wash their faces and res-pirator
facepieces whenever necessary to prevent skin
irritation associated with respirator use.
25
Table 2
Respiratory Protection for Lead Aerosols
26
Not in excess of 2,500 μg/ m3
( 50 X PEL)
Full- facepiece air- purifying respirator with
high- efficiency filters.#
Tight- fitting powered air- purifying respirator
with high- efficiency filters.#
Full- facepiece supplied- air respirator operated
in demand mode.
Half- mask or full- facepiece supplied- air
respirator operated in continuous- flow mode.
Full- facepiece self- contained breathing
apparatus ( SCBA) operated in demand mode.
Greater than 100,000 μg/ m3,
unknown concentration, or
firefighting
Full- facepiece SCBA operated in pressure-demand
or other positive- pressure mode.
Not in excess of 500 μg/ m3
( 10 X PEL)
Half- mask air- purifying respirator with high-efficiency
filters.†#
Half- mask supplied- air respirator operated in
demand ( negative- pressure) mode.
Airborne Concentration of
Lead or Condition of Use Required Respirator*
Not in excess of 1,250 μg/ m3
( 25 X PEL)
Not in excess of 50,000 μg/ m3
( 1,000 X PEL)
Not in excess of 100,000 μg/ m3
( 2,000 X PEL)
Loose fitting hood or helmet powered air-purifying
respirator with high- efficiency filters.#
Hoods or helmet supplied- air respirator
operated in continuous- flow mode— for
example, type CE abrasive blasting respirators
operated in a continuous- flow mode.
Half- mask supplied- air respirator operated in
pressure- demand or other positive- pressure
mode.
Full- facepiece supplied- air respirator
operated in pressure- demand or other
positive- pressure mode— for example,
type CE abrasive blasting respirators
operated in a positive- pressure mode.
Source: “ Lead Exposure in Construction; Interim Final Rule,” Federal Register 58( 84): 26630, May 4, 1993.
* Respirators specified for higher concentrations can be used at lower concentrations of lead.
† Full facepiece is required if the lead aerosols cause eye or skin irritation at the use concentrations.
# A high- efficiency particulate air filter means a filter that is 99.97 percent efficient against particles of 0.3
micron or larger.
If exposure monitoring or experience indicates
airborne exposures to contaminants other than lead,
such as solvents or polyurethane coatings, these expo-sures
must be considered when selecting respiratory
protection. A reevaluation of the respiratory protection
program is required when a worker demonstrates a con-tinued
increase in blood lead levels.
Abrasive Blasting and Related
Operations
NIOSH type CE respirators are required for use by
abrasive blasting operators. Currently, NIOSH certifies
both continuous flow and positive pressure respirators
for abrasive blasting operations. The continuous flow
respirators are recommended by NIOSH only for air-borne
concentrations less than or equal to 25 times 3 the
OSHA PEL of 50 μg/ m3. Positive pressure respirators
are recommended by NIOSH for airborne concentra-tions
less than 2,000 times the OSHA PEL of 50 μg/ m3.
Furthermore, manufacturer’s instructions regarding
quality of air, air pressure, inside diameter of hoses,
and length of hoses must be strictly followed. Use of
longer hoses or smaller inside diameter hoses than the
manufacturer’s specifications or hoses with bends or
kinks may restrict the flow of air to a respirator.
27
________
3Type CE continuous flow respirators used in abrasive blasting that are
manufactured by E. D. Bullard Company ( Models 77 and 88) and CLEMCO
Industries Corporation ( Apollo 20 and Apollo 60) are acceptable in atmos-pheres
where the airborne level does not exceed 50,000 μg/ m3 ( 1,000 times
the PEL) of lead in air. The relief for these two models applies only to lead
in construction. The Assigned Protection Factor ( APF) of 1,000 does not
apply to other air contaminants. Therefore, if silica sand is used as the
blasting agent, the APF reverts back to 25 times the PEL ( 1,250 μg/ m3).
8
Medical Assessment and
Recordkeeping
When a construction employee is occupationally
exposed to lead at or above the action level of 30 μg/ m3
on any one day in a calendar year, the employee must
be provided initial medical surveillance consisting of
biological monitoring in the form of blood sampling and
analysis for lead and zinc protoporphyrin levels. Blood
lead levels are currently the best indicator of personal
lead exposure. Workers potentially exposed to lead at or
above the action level must be monitored for the
presence of lead in the blood and the effects of lead on
the blood- forming system. Full medical surveillance is to
be provided to employees exposed to lead at or above the
action level for more than 30 days per year. All medical
examinations and consultations must be performed by or
under the direct supervision of a qualified physician and
must be provided to employees at no cost, without loss of
pay, and at a reasonable time and place. A qualified
physician is a doctor of medicine ( M. D.) or osteopathy
( D. O.) familiar with the objectives and requirements of a
medical surveillance program for lead exposure.
The following conditions necessitate an immediate
medical consultation including, as determined by the
qualified physician, a physical examination and a blood
sample for lead analysis ( biological monitoring):
• Whenever a worker develops signs or symptoms
associated with lead toxicity.
• Before a worker restarts work following medical
removal.
28
The employer must maintain any employee exposure
and medical records to document ongoing employee
exposure, medical monitoring, and medical removal of
workers. These data provide a base to properly evaluate
the employee’s health. In addition, employees or former
employees, their designated representatives, and OSHA
must be provided access to exposure and medical
records.
Biological Monitoring
The purpose of biological monitoring is to identify
workers with elevated blood lead levels. The data from
biological monitoring are objective evidence of a work-er’s
body burden from lead exposure. These data can be
used to follow changes in worker exposure. Blood lead
and zinc protoporphyrin ( ZPP) or free erythrocyte proto-porphyrin
( FEP) must be monitored for those workers
exposed to lead. In general, workers in high- risk occu-pations
should be monitored as often as needed to pre-vent
adverse health effects.
Reproductive Hazard Issues
Lead is toxic to both male and female reproductive
systems. Workers who are actively seeking to have a
child or who are pregnant should contact qualified med-ical
personnel to arrange for a job evaluation and med-ical
follow- up. Employers who have been contacted by
employees with concerns about reproductive issues
should refer them to qualified medical personnel.
Medical Surveillance
The employer must institute a medical surveillance
program for all employees who are or may be exposed
above the action level for more than 30 days per year.
The employer must maintain an accurate record for
each employee subject to medical surveillance to include
29
a description of the employee’s duties; a copy of the
physician’s written opinions; the results ( as supplied to
the examining physician) of any airborne exposure mon-itoring
done for the representative employee and all
others represented; and any employee medical
complaints related to lead exposure.
The employer must obtain and furnish to the
employee the physician’s written opinion. This opinion
should contain the results of the medical examination
as they relate to occupational exposure to lead and
must include:
• Whether the employee has any detected medical
condition that would place his/ her health at
increased risk from lead exposure.
• Any special protective measures or limitations on
worker’s exposure to lead.
• Any limitation on respirator use.
• Results of blood lead determination.
• A statement that the employee has been informed
by the physician of the results of the consultation
or medical examination and any medical condition
that may require further examination or
treatment.
Findings of lab results or diagnoses unrelated to the
worker’s exposure to lead must not be communicated to
the employer or included in a written opinion. Employees
should be advised by each physician of any medical con-dition,
occupational or nonoccupational, that necessitates
further medical evaluation or treatment. The employer
must furnish the employee with a copy of the written
medical opinion.
In addition, the employer must keep or ensure that
the examining physician keeps the following medical
records: a copy of the medical examination results
30
including medical and work history; a description of the
laboratory procedures and a copy of any guidelines used
to interpret the test results; and a copy of the results of
biological monitoring.
Chelation
The use of chelating drugs as a prophylactic measure
( i. e., to prevent a detectable rise in blood lead) is an
unacceptable medical practice. Chelation may be used
by a qualified physician only for diagnostic or therapeu-tic
reasons ( that is, to diagnose or treat the signs and
symptoms of severe lead toxicity).
Medical Removal
Medical removal will protect worker health both by
stopping further occupational exposure and by enabling
the worker to excrete the absorbed lead naturally. With
good engineering, work practices, personal hygiene, and
respiratory protection practices in place, very few
employees should reach the medical removal trigger
level specified in the OSHA standard. OSHA’s interim
final standard for lead in construction uses a medical
removal trigger level of 50 μg/ dl. However, some author-ities
believe that medical removal should take place at
lower levels.
When employees are removed, or otherwise limited,
they must be placed in jobs that will not result in expo-sure
to lead at or above the action level of 30 μg/ m3. The
employer may return the employee to his or her former
job status when a qualified physician’s medical determi-nation
is that the employee is no longer at risk from
exposure to lead or when the employee’s blood lead level
drops below 40 μg/ dl.
In the case of medical removal, records must include
the following information:
31
• The name and social security number of the worker.
• The date of each occasion that the worker was
removed from current exposure to lead.
• The date on which the worker was returned to his
or her former job status.
• A brief explanation of how each removal was or is
being accomplished.
• A statement indicating whether the reason for the
removal was an elevated blood lead level.
The employer must maintain these records for at
least the duration of any worker’s employment.
Recordkeeping
The employer must establish and maintain an accu-rate
record of all monitoring and other data used to con-duct
employee exposure assessments in accordance with
provisions in 29 CFR 1926.62( n). The following must be
included in exposure monitoring records:
• The dates, number, duration, location, and results
of each sample taken, including a description of
the sampling procedure used to determine repre-sentative
employee exposure.
• A description of the sampling and analytical
methods used and evidence of their accuracy.
• The type of respiratory protection worn, if any.
• The name, social security number, and job classifi-cation
of the monitored employee and all others
whose exposure the measurement represents.
• Environmental variables that could affect the
measurement of employee exposure.
32
Employers must properly record cases on their OSHA
form 200 when the worker:
• Has a blood lead level that exceeds 50 μg/ dl.
• Has symptoms of lead poisoning, such as colic,
nerve damage, renal damage, anemia, or gum
problems.
• Receives medical treatment to lower blood lead
levels or for lead poisoning.
In addition, employees or former employees, their
designated representatives, and OSHNC must be pro-vided
access to exposure and medical records in accor-dance
with 29 CFR 1910.20. When an employer ceases
to do business, the successor employer must receive and
retain all required records.
33
The following industry guides are available from the N. C. Department of Labor’s Division of Occupational
Safety and Health:
1# 1. A Guide to Safety in Confined Spaces
1# 2. A Guide to Procedures of the Safety and Health Review Board of North Carolina
1# 3. A Guide to Machine Safeguarding
1# 4. A Guide to OSHA in North Carolina
1# 5. A Guide for Persons Employed in Cotton Dust Environments
1# 6. A Guide to Lead Exposure in the Construction Industry
1# 7. A Guide to Bloodborne Pathogens in the Workplace
1# 8. A Guide to Voluntary Training and Training Requirements in OSHA Standards
1# 9. A Guide to Ergonomics
# 10. A Guide to Farm Safety and Health
# 11. A Guide to Radio Frequency Hazards With Electric Detonators
# 12. A Guide to Forklift Operator Training
# 13. A Guide to the Safe Storage of Explosive Materials
# 14. A Guide to the OSHA Excavations Standard
# 15. A Guide to Developing and Maintaining an Effective Hearing Conservation Program
# 17. A Guide to Asbestos for Industry
# 18. A Guide to Electrical Safety
# 19. A Guide to Occupational Exposure to Wood, Wood Dust and Combustible Dust Hazards
# 20. A Guide to Crane Safety
# 21. A Guide to School Safety and Health
# 23. A Guide to Working With Electricity
# 25. A Guide to Personal Protective Equipment
# 26. A Guide to Manual Materials Handling and Back Safety
# 27. A Guide to the Control of Hazardous Energy ( Lockout/ Tagout)
# 28. A Guide to Eye Wash and Safety Shower Facilities
# 29. A Guide to Safety and Health in Feed and Grain Mills
# 30. A Guide to Working With Corrosive Substances
# 31. A Guide to Formaldehyde
# 32. A Guide to Fall Prevention in Industry
# 33. A Guide to Office Safety and Health
# 34. A Guide to Safety and Health in the Poultry Industry
# 35. A Guide to Preventing Heat Stress
# 36. A Guide to the Safe Use of Escalators and Elevators
# 37. A Guide to Boilers and Pressure Vessels
# 38. A Guide to Safe Scaffolding
# 39. A Guide to Safety in the Textile Industry
# 40. A Guide to Emergency Action Planning
# 41. A Guide to OSHA for Small Businesses in North Carolina
Occupational Safety and Health ( OSH)
Sources of Information
You may call 1- 800- NC- LABOR ( 1- 800- 625- 2267) to reach any division of the N. C. Department of Labor; or visit the
NCDOL home page on the World Wide Web, Internet Web site address: http:// www. nclabor. com.
N. C. Division of Occupational Safety and Health
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 3rd Floor)
Local Telephone: ( 919) 807- 2900 Fax: ( 919) 807- 2856
For information concerning education, training and interpretations of occupational safety and health standards contact:
Bureau of Education, Training and Technical Assistance
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 4th Floor)
Telephone: ( 919) 807- 2875 Fax: ( 919) 807- 2876
For information concerning occupational safety and health consultative services and safety awards programs contact:
Bureau of Consultative Services
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 3rd Floor)
Telephone: ( 919) 807- 2899 Fax: ( 919) 807- 2902
For information concerning migrant housing inspections and other related activities contact:
Agricultural Safety and Health Bureau
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 2nd Floor)
Telephone: ( 919) 807- 2923 Fax: ( 919) 807- 2924
For information concerning occupational safety and health compliance contact:
Safety and Health Compliance District Offices
Raleigh District Office ( 313 Chapanoke Road, Raleigh, NC 27603)
Telephone: ( 919) 779- 8570 Fax: ( 919) 662- 4709
Asheville District Office ( 204 Charlotte Highway, Suite B, Asheville, NC 28803- 8681)
Telephone: ( 828) 299- 8232 Fax: ( 828) 299- 8266
Charlotte District Office ( 901 Blairhill Road, Suite 200, Charlotte, NC 28217- 1578)
Telephone: ( 704) 665- 4341 Fax: ( 704) 665- 4342
Winston- Salem District Office ( 4964 University Parkway, Suite 202, Winston- Salem, NC 27106- 2800)
Telephone: ( 336) 776- 4420 Fax: ( 336) 776- 4422
Wilmington District Office ( 1200 N. 23rd St., Suite 205, Wilmington, NC 28405- 1824)
Telephone: ( 910) 251- 2678 Fax: ( 910) 251- 2654
*** To make an OSHA Complaint, OSH Complaint Desk: ( 919) 807- 2796***
For statistical information concerning program activities contact:
Planning, Statistics and Information Management
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 2nd Floor)
Telephone: ( 919) 807- 2950 Fax: ( 919) 807- 2951
For information about books, periodicals, vertical files, videos, films, audio/ slide sets and computer databases contact:
N. C. Department of Labor Library
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 5th Floor)
Telephone: ( 919) 807- 2848 Fax: ( 919) 807- 2849
N. C. Department of Labor ( Other than OSH)
1101 Mail Service Center
Raleigh, NC 27699- 1101
Telephone: ( 919) 733- 7166 Fax: ( 919) 733- 6197

Click tabs to swap between content that is broken into logical sections.

A Guide to
Lead Exposure in the
Construction Industry
Sydney Cheryl Sutton
Editor
N. C. Department of Labor
Division of Occupational Safety and Health
1101 Mail Service Center
Raleigh, NC 27699- 1101
Cherie K. Berry
Commissioner of Labor
Acknowledgments
A Guide to Lead Exposure in the Construction Industry is
based upon the U. S. Department of Labor’s Program
Highlights fact sheet series ( Fact Sheet No.’ s OSHA 93- 47
through 93- 52) concerning the topic of lead in construction,
combined with information from a U. S. OSHA booklet
titled Lead in Construction ( OSHA 3142). Additional mate-rial
was provided by North Carolina Department of Labor
Health Standards Officer J. Edgar Geddie, Ph. D., and
Health Compliance Supervisor Paul Sullivan.
This guide is intended to be consistent with all existing
OSHA standards; therefore, if an area is considered by
the reader to be inconsistent with a standard, then the
OSHA standard should be followed.
To obtain additional copies of this book, or if you have ques-tions
about N. C. occupational safety and health standards
or rules, please contact:
N. C. Department of Labor
Bureau of Education, Training and Technical Assistance
1101 Mail Service Center
Raleigh, NC 27699- 1101
Phone: ( 919) 807- 2875 or 1- 800- NC- LABOR
____________________
Additional sources of information are listed
on the inside back cover of this book.
____________________
The projected cost of the OSHNC program for federal fiscal year 2002– 2003 is $ 13,130,589.
Federal funding provides approximately 37 percent ($ 4,920,000) of this total.
Printed 12/ 97, 3M
N. C. Department of Labor
Occupational Safety and Health Program
Cherie K. Berry
Commissioner of Labor
OSHA State Plan Designee
Allen McNeely
Deputy Commissioner for Safety and Health
Kevin Beauregard
Assistant Deputy Commissioner for Safety and Health
Contents
Part Page
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iiv
1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11
2 Worker Protection Programs . . . . . . . . . . . . . . . . .14
3 Exposure Assessment . . . . . . . . . . . . . . . . . . . . . . . . .17
4 Engineering Controls . . . . . . . . . . . . . . . . . . . . . . . . . . 11
5 Housekeeping and Personal
Hygiene Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
6 Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
7 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . 23
8 Medical Assessment and Recordkeeping.... 28
iii
Foreword
Lead is a cumulative and toxic substance. People who
swallow or inhale lead compounds may become ill or die
from lead poisoning. Although lead is eliminated from
the body at a slow rate, inhaling even a small amount of
a lead compound over an extended period of time may
cause lead poisoning. Immediate symptoms of disease
may not be noticeable. As the blood is circulated
through the body, lead is stored in various organs and
body tissues. The lead stored in the body may be slowly
causing irreversible damage: first to the cells, then to
the organs, and finally to the whole body system.
Employers must be aware of workplace hazards fac-ing
their workers and must take appropriate action to
minimize or eliminate exposure to these hazards. A
Guide to Lead Exposure in the Construction Industry
discusses precautions that can prevent serious health
risks to workers due to exposure to lead compounds.
In this state, North Carolina Department of Labor
consultants and inspectors administer the federal
OSHA laws through a plan approved by the U. S.
Department of Labor. All current OSHA standards are
enforced. Many educational programs, publications
( including this guide), and other services are also
offered to help inform people about their rights and
responsibilities regarding OSHA.
As you look through this guide, please remember that
OSHA’s mission is greater than just enforcement. An
equally important goal is to help citizens find ways to
create safe and healthy workplaces. Reading and using
the information in this booklet, like other educational
materials produced by the North Carolina Department
of Labor, can help.
Cherie K. Berry
Commissioner of Labor
iv
1
Introduction
Health Hazards of Lead Exposure in
the Construction Industry
Pure lead ( Pb) is a heavy metal ( at room temperature
and pressure) and is a basic chemical element. It can
combine with various other substances to form numer-ous
lead compounds. When absorbed into the body in
certain doses lead is toxic. It can be absorbed into the
body by inhalation and ingestion. Except for certain
organic lead compounds not covered by OSHA’s interim
1926.62 standard, lead is not absorbed significantly
through the skin. When scattered through the air as a
dust, fume, or mist, lead can be inhaled and absorbed
through the lungs and upper respiratory tract.
Inhalation of airborne lead is generally the most impor-tant
source of occupational lead absorption. Lead also
can be absorbed through the digestive system if it
enters the mouth and is ingested.
A significant portion of the lead inhaled or ingested
gets into the blood stream. Once in the blood stream,
lead is circulated through the body and stored in various
organs and body tissues. Some of this lead is quickly
filtered out of the body and excreted, but some remains
in the blood and tissues. As exposure continues, the
amount stored will increase if the body is absorbing
more lead than it is excreting. The lead stored in the
tissues can slowly cause irreversible damage, first to
individual cells, then to organs and whole body systems.
1
Long- term ( chronic) overexposure to lead may result
in severe damage to the blood- forming, nervous,
urinary, and reproductive systems. Some common
symptoms include the following:
Damage to the central nervous system in general and
the brain in particular is one of the most severe forms of
lead poisoning. Chronic overexposure to lead also signif-icantly
impairs the reproductive systems of both men
and women. Lead can alter the structure of sperm cells,
raising the risk of birth defects, and there is evidence of
miscarriage and stillbirth in women exposed to lead or
whose husbands have been exposed to lead. Children
born of parents who were exposed to excess lead levels
are more likely to have birth defects, mental
retardation, behavioral disorders, or to die during the
first year of childhood.
The interim OSHA standard aims to reduce the expo-sure
to lead for construction workers. The most signifi-cant
way to achieve this is by lowering the permissible
exposure limit ( PEL) from 200 micrograms per cubic
meter of air ( 200 μg/ m3) as an 8- hour time weighted
average ( TWA) to 50 μg/ m3.
For the purpose of this standard, lead includes
metallic lead, all inorganic lead compounds, and organic
lead soaps. OSHA’s lead in construction standard
applies to all construction work where an employee may
be occupationally exposed to lead. All work related to
2
loss of appetite
constipation
excessive tiredness
headache
fine tremors
colic with severe
abdominal pain
metallic taste
nervous irritability
hyperactivity
muscle and joint pain
or soreness
weakness
anxiety
pallor
insomnia
numbness
dizziness
construction, alteration, or repair, including painting
and decorating, is included.
Engineering and Work Practice
Controls
The lead in construction standard requires employers
to use, when feasible, engineering and work practice
controls to reduce and maintain employee lead exposure
to or below the PEL. When all feasible controls have
been instituted but are not sufficient to reduce employ-ee
exposure to or below the PEL, they must be used to
reduce exposure to the lowest feasible level and supple-mented
by respirators.
Engineering controls reduce employee exposure in
the workplace either by removing or isolating the haz-ard
or isolating the worker from exposure through the
use of technology. Under the lead in construction stan-dard,
mechanical ventilation may be used to control
lead exposure. If used, the employer must evaluate, as
necessary, the mechanical performance of the system in
controlling exposure to maintain its effectiveness.
Work practice controls reduce the likelihood of
exposure by altering the manner in which a task is
performed. Safe work practices under the lead in con-struction
standard include, but are not limited to,
maintaining separate hygiene facilities ( i. e., change
rooms, showers, hand washing facilities, and lunch
areas) and requiring proper housekeeping practices
( i. e., cleanup methods).
3
2
Worker Protection Programs
Lead has been poisoning workers for thousands of
years. Traditionally, most over- exposures to lead in the
construction industry have been found in the trades,
such as plumbing, welding, and painting.
In building construction, lead is frequently used for
roofs, cornices, tank linings, and electrical conduits. In
plumbing, soft solder, used chiefly for soldering tinplate
and copper pipe joints, is an alloy of lead and tin. Soft sol-der,
in fact, has been banned for many uses in the United
States. The use of lead- based paint in residential applica-tion
has been banned by the Consumer Product Safety
Commission. However, since lead- based paint inhibits the
rusting and corrosion of iron and steel, it is still used on
bridges, railways, ships, lighthouses, and other steel
structures, although substitute coatings are available.
Significant lead exposures can also arise from remov-ing
paint from surfaces previously coated with lead-based
paint, such as in bridge repair, residential reno-vation,
and demolition. With the increase in highway
work, including bridge repair, residential lead
abatement, and residential remodeling, the potential for
exposure to lead- based paint has become more common.
The trades potentially exposed to lead include iron
work, demolition work, painting, lead- based paint
abatement work, plumbing, heating/ air- conditioning,
electrical work, and carpentry/ renovation/ remodeling.
Operations that generate lead dust and fumes
include the following:
✦ Flame- torch cutting, welding, the use of heat guns,
sanding, scraping and grinding of lead painted sur-faces
in repair, reconstruction, dismantling, and
demolition work.
4
✦ Abrasive blasting of bridges and other structures
containing lead- based paints.
✦ Use of torches and heat guns, and sanding, scrap-ing,
and grinding lead- based paint surfaces during
remodeling or abating lead- based paint.
✦ Maintaining process equipment or exhaust duct
work.
The employer of construction workers is responsible
for the development and implementation of a worker
protection program in accordance with 29 CFR 1926.20
and 29 CFR 1926.62. This program is essential in mini-mizing
worker risk of lead exposure. Construction pro-jects
vary in their scope and potential for exposing
workers to lead and other hazards. Many projects may
involve limited exposure, such as the removal of paint
from a few interior residential doors. Others may
involve the removal, or stripping off, of substantial
quantities of lead- based paints on large bridges. The
employer should, as needed, consult a qualified safety
and health professional 1 to develop and implement an
effective worker protection program.
The most effective way to protect workers is to mini-mize
exposure through the use of engineering controls
and good work practices. It is OSHA policy that respira-tors
are not to be used in lieu of engineering and work
practice controls to reduce employee exposures to or
below the PEL. Respirators can only be used in combi-nation
with engineering controls and work practices to
control employee exposures. OSHA’s interim final stan-dard
for lead in construction limits worker exposures to
50 micrograms of lead per cubic meter of air averaged
over an eight- hour workday.
5
________
1Sources for professional safety and health advice include insurance
carriers, trade organizations, state 7( c)( 1) on- site consultation programs,
and consultants.
At the minimum, the following elements should be
included in the employer’s worker protection program
for employees exposed to lead:
✦ Hazard determination, including exposure assess-ment,
( see Lead- Related Tasks Regarding Interim
Worker Exposure in Part 3, Table 1 in this guide)
✦ Engineering and work practice controls
✦ Respiratory protection
✦ Protective clothing and equipment
✦ Housekeeping
✦ Hygiene facilities and practices
✦ Medical surveillance and provisions for medical
removal
✦ Training
✦ Signs
✦ Recordkeeping
To implement the worker protection program properly,
the employer needs to designate a competent person ( one
who is capable of identifying existing and predictable
hazards or working conditions that are hazardous or
dangerous to employees, in accordance with the general
safety and health provisions of OSHA’s construction
standards). The competent person must have the autho-rization
to take prompt corrective measures to eliminate
such problems. Qualified medical personnel must be
available to advise the employer and employees on the
health effects of employee lead exposure and supervise
the medical surveillance program.
6
3
Exposure Assessment
Assessing Exposures
Where initial employee exposure is at or above the
action level ( 30 μg/ m3), the employer must collect per-sonal
samples representative of a full work shift,
including at least one sample for each shift or for the
shift with the highest exposure level for each job classi-fication
in each work area. These samples must repre-sent
the monitored employee’s regular daily exposure to
lead. Measurements made within the previous 12
months may be used to determine how far above the
action level employee exposure may be.
An initial determination of whether employees are
exposed to lead at or above the action level and the
results of that determination must be made available
based on the following:
• Any information, observation, or calculation that
indicates employee exposure to lead.
• Any previous measurements of airborne lead.
• Any employee complaints of symptoms attributable
to lead exposure.
• Objective data regarding materials, processes, or
operations.
The employer may discontinue required monitoring
when at least two consecutive measurements, taken at
least seven days apart, are below the action level.
Monitoring for the initial determination whether
employees are exposed at or above the action level may
be limited to a representative sample of those employees
exposed to the greatest concentrations of airborne lead.
7
Measurements made within the preceding 12 months,
which were performed by the same employer and applic-able
to the same employee tasks, may be used.
The employer must establish and maintain an accu-rate
record documenting the nature and relevancy of
previous exposure data. Instead of performing initial
monitoring, the employer may rely on objective data to
demonstrate that a particular lead- containing material
or product does not result in employee exposure at or
above the action level when in use, being processed, or
handled.
Until the employer performs an exposure assessment
and documents that employees are not exposed above
the PEL, the employer must treat employees who per-form
certain operations as if they were exposed above
the PEL. This means that the employer must provide
respiratory protection, protective work clothing and
equipment, change areas, hand washing facilities, bio-logical
monitoring, and training for employees perform-ing
these “ trigger” tasks. Table 1, in this section,
provides a list of the lead- related tasks that require
interim protection and a description of each of those
operations.
For an initial determination that indicates no
employee is exposed at or above the action level ( 30
��g/ m3), the employer must keep a written record of the
determination, including the date, location within the
work site, and the name and social security number of
each monitored employee.
Monitoring and Observing
If the initial determination proves employee exposure
is below the action level, further exposure determina-tion
need not be repeated unless there is a change in
processes or controls. If employee exposure is at or
above the action level, but at or below the PEL, the
8
employer must perform monitoring at least every six
months and continue until at least two consecutive
measurements, taken at least seven days apart, are
below the action level.
If employee exposure is above the PEL, the employer
must perform monitoring quarterly and continue until
at least two consecutive measurements, taken at least
seven days apart, are at or below the PEL but at or
above the action level. The employer then must repeat
and continue monitoring every six months to bring the
exposure to or below the action level as described above.
Whenever there is a change of equipment, process,
control, personnel, or a new task has been initiated that
could increase employee lead exposure at or above the
action level, the employer must conduct additional mon-itoring.
The employer must notify each employee in writing of
employee exposure assessment results within five work-ing
days after their receipt. Whenever the results indi-cate
that the representative employee exposure, with-out
the use of respirators, is at or above the PEL, the
employer must include a written notice stating that the
employee’s exposure was at or above that level and
describing the corrective action taken or to be taken to
reduce exposure below that level.
The employer must provide affected employees or
their designated representatives an opportunity to
observe any monitoring of employee lead exposure. This
includes providing and ensuring the use of respirators
and protective clothing and equipment whenever moni-toring
requires entry into an area where such is
required. The observer is entitled to an explanation
of the measurement procedures, to observe all steps
related to lead monitoring performed at the place of
exposure, and to record the results obtained or receive
copies of the results when returned by the laboratory.
9
Table 1
Lead- Related Tasks Requiring Interim Worker Protection
10
Abrasive blasting
Welding, cutting,
and burning on steel
structures
Lead burning
Manual scraping and
sanding
Manual demolition of
structure
Heat gun application
Using lead containing
mortar
Abrasive blasting
enclosure movement
and removal
Power tool cleaning
Rivet busting
Cleanup activities
where dry expendable
abrasives are used
Removal of scale, paint, and dirt from surfaces
prior to repainting; abrasive media includes sand,
steel grit, aluminum oxide, “ Black Beauty”
( processed boiler slag), and others.
Process of heating coated steel to its melt
temperature typically using an oxyacetylene
torch or arc welder.
Involves torch melting or fusing of lead or alloyed
lead to another lead object.
Associated with lead paint removal and involves
application of hand- held scraping or sanding tool to
the painted surface containing lead.
Involves removal of walls ( plaster, gypsum) or
building components coated with lead- based paint
that is subsequently scraped off.
Use of a heat gun that produces a stream of hot
air directed to surfaces to melt lead paint that is
subsequently scraped off.
Used in high pressure acid tanks lined with
specialized tile of lead brick held in place with
specialized lead- containing mortar or grout; these
tank linings periodically require repainting, repair-ing,
or relining involving lead containing mortar.
Movement and removal of blasting enclosure or
containment units as work proceeds on structures;
such units are often composed of flexible nylon,
plastic, or burlap tarpaulins upon which lead dust
will accumulate and be retained when movement
of the structure occurs.
Removal of rivets from steel structures where lead-containing
paints are present; rivet busting can
involve use of torches and mechanical means for
rivet extraction.
Use of power tools ( grinders, brushes, needle
guns, sanders, etc.) to remove dirt, scale, or paint
from structures where lead- based paint is present.
Use of non- recycled dry abrasives during abrasive
blasting operations on structures where lead-containing
paint is found.
4
Engineering Controls
Lead is a cumulative and persistent toxic substance.
Lead- caused health effects may result from low levels of
exposure over prolonged periods of time. Engineering
controls and good work practices must be used where
feasible to minimize employee exposure to lead. At a
minimum, exposures must not exceed the OSHA interim
final PEL of 50 micrograms per cubic meter of air ( 50
μg/ m3) averaged over an 8- hour period. When feasible
engineering controls and work practice controls cannot
reduce worker exposure to lead at or below 50 μg/ m3,
respirators must be used to supplement engineering and
work practice controls.
A competent person 2 should review all site operations
and stipulate the specific engineering controls and work
practices designed to reduce worker exposure to lead.
Engineering measures include local and general exhaust
ventilation, process and equipment modification, materi-al
substitution, component replacement, and isolation
or automation. Examples of recommended engineering
controls that can be used to reduce worker exposure to
lead are as follows:
Exhaust Ventilation
Power tools used for the removal of lead- based paint
should be equipped with dust collection shrouds or
other attachments exhausted through a high- efficiency
particulate air ( HEPA) vacuum system. Operations
such as welding, cutting/ burning, or heating should be
11
________
2One who is capable of identifying existing and predictable lead hazards in
the surroundings or working conditions and who has authorization to take
prompt corrective measures to eliminate them.
provided with local exhaust ventilation. HEPA vacuums
should be used during cleanup activities.
For abrasive blasting operations where full contain-ment
exists or is required, the containment structure
should be designed to optimize the flow of ventilation
air past the worker( s), so that the airborne concentra-tion
of lead is reduced and the visibility is increased.
The affected area should be maintained under negative
pressure to reduce the chances that lead dust will cont-aminate
areas outside the enclosure. A containment
structure should be equipped with dust collection and
an air- cleaning device to control emissions of
particulate matter to the environment.
Enclosure/ Encapsulation
Lead- based paint can be made inaccessible either by
encapsulating it with a material that bonds to the sur-face,
such as acrylic or epoxy coating or flexible wall cov-erings,
or by enclosing it using systems such as gypsum
wallboard, plywood paneling, and aluminum, vinyl or
wood exterior siding. Floors coated with lead- based
paint can be covered using vinyl tile or linoleum flooring.
The building owner, or other responsible person,
should oversee the custodial and maintenance staffs
and contractors with regard to all activities that involve
enclosed or encapsulated lead- based paint. This will
minimize potential inadvertent release of lead during
maintenance, renovation, or demolition.
Substitution
Zinc- containing primers covered by an epoxy interme-diate
coat and polyurethane topcoat are commonly used
instead of lead- containing coatings.
Mobile hydraulic shears can be substituted for torch
cutting under certain circumstances.
12
Surface preparation equipment, such as needle guns
with multiple reciprocating needles completely enclosed
within an adjustable shroud, can be substituted for
abrasive blasting under certain operations. The shroud
captures dust and debris at the cutting edge and can be
equipped with a HEPA vacuum filtration system with a
self- drumming feature. One such commercial unit can
remove lead- based paint from flat steel and concrete
surfaces, outside edges, inside corners, and pipes.
Chemical strippers, used primarily on the exterior of
buildings, surfaces involving carvings or molding, or
intricate iron works, can be used in place of hand scrap-ing
using a heat gun. Chemical removal generates less
airborne lead dust; however, these strippers can be haz-ardous.
The material safety data sheets ( MSDSs) for
the products used must be reviewed by the employer for
information on worker exposure hazards from the
chemical ingredients and protective measures
recommended by the manufacturer.
Component Replacement
Lead- base painted building components ( i. e.,
windows, doors, and trim) can be replaced either with
new components free of lead- containing paint or with
the same components after the paint has been removed
off- site. Replacement is a permanent solution.
Process/ Equipment Modification
Brush/ roller application of lead paints or other lead-containing
coatings is a safer method than spraying.
This method of application introduces little or no paint
mist into the air where the mist can present a lead
inhalation hazard. ( Note: There is a ban on the use of
lead- based paint in residential housing.)
Non- silica containing abrasive ( e. g., steel or iron
shot/ grit) should be used, where practical, instead of
13
sand in abrasive blasting operations. When sand is
used, the free silica portion of the dust presents a signif-icant
respiratory health hazard.
Blasting techniques that are less dusty than abrasive
blasting and that can be effective under some conditions
include: ( 1) hydro- or wet- blasting ( using high- pressure
water with or without abrasive, or surrounding the
blast nozzle with a ring of water) and ( 2) vacuum blast-ing
where a vacuum hood for material removal is posi-tioned
around the exterior of the blasting nozzle.
Heat guns used to remove lead- based paints in resi-dential
housing units should be of the flameless electri-cal
softener type. Heat guns should have electronically
controlled temperature settings to allow usage below
700 degrees F. Heat guns should be equipped with vari-ous
nozzles to cover all common applications and to
limit the heated work area.
When using abrasive blasting with vacuum hood on
exterior building surfaces, care should be taken that the
configuration of the heads on the blasting nozzle match
the configuration of the substrate, so that the vacuum is
effective in containing debris.
Since HEPA vacuum cleaners can be used to clean
surfaces other than just floors, operators should have
attachments appropriate for use on unusual surfaces.
The proper use of brushes of various sizes and crevice
and angular tools, when needed, will enhance the quality
of the HEPA- vacuuming process and help reduce the
amount of lead dust released into the air.
Isolation
Although it is not feasible to completely enclose
and ventilate some abrasive blasting operations, it
is possible to isolate many operations to help reduce
the potential for exposure to lead. Isolation, in this
instance, consists of keeping employees not involved
14
in the blasting operations as far away as possible from
the work area. By placing the employees a greater dis-tance
from the source of lead exposure, their exposures
will be reduced.
15
5
Housekeeping and Personal
Hygiene Practices
Lead is a cumulative and persistent toxic substance
that poses a serious health risk. A rigorous housekeep-ing
program and adherence to basic personal hygiene
practices will minimize employee exposure to lead. In
addition, these two elements of the worker protection
program will help to prevent taking lead- contaminated
dust out of the worksite and home to the workers’ fami-lies,
thus ensuring that the duration of lead exposure
does not extend beyond the workshift and providing
added protection to employees and their families.
Housekeeping
An effective housekeeping program involves at least
daily removal of accumulations of lead dust and lead-containing
debris. Vacuuming lead dust with high-efficiency
particulate air ( HEPA) filtered equipment
or wetting it with water before sweeping are effective
control measures. Such cleaning operations should be
conducted, whenever possible, at the end of the day,
after normal operations cease. Furthermore, all
persons doing the cleanup should be provided with
suitable respiratory protection and personal protective
clothing to prevent contact with lead.
In addition, all lead- containing debris and contami-nated
items accumulated for disposal should be collected
and put into sealed impermeable bags or other closed
impermeable containers. Bags and containers should
be appropriately labeled as lead- containing waste.
These measures are especially important as they mini-mize
additional sources of exposure that engineering
16
controls generally are not designed to control. Disposal
of lead- containing waste should be done in accordance
with federal, state, and local government regulations.
Personal Hygiene Practices
To minimize exposure to lead, special attention should
be given to workers’ personal hygiene. The employer
must provide and ensure that workers use washing
facilities. Clean change areas and separate noncontami-nated
eating areas must also be provided. Cars should
be parked where they will not be contaminated with
lead. These measures will reduce the worker’s period of
exposure to lead and the ingestion of lead, ensure that
the duration of lead exposure does not extend beyond
the workshift, significantly reduce the movement of lead
from the worksite, and provide added protection to
employees and their families.
Change areas: The employer must provide a clean
change area for employees exposed above the permissi-ble
exposure limit or who are performing certain “ trig-ger”
tasks. ( See Table 1 in Part 3 of this guide.) The
change area must be equipped with storage facilities for
street clothes and a separate area with facilities for the
removal and storage of lead- contaminated protective
work clothing and equipment. This separation is essen-tial
in preventing cross contamination of the employee’s
clothing.
Clean change areas are to be used for taking off
street clothes, suiting up in clean working clothes ( pro-tective
clothing), donning respirators prior to beginning
work, and dressing in street clothes after work. No lead-contaminated
items should enter this area.
Work clothing must not be worn away from the job
site. Under no circumstances should lead- contaminated
work clothes be laundered at home or taken from the
17
worksite, except to be laundered professionally or prop-erly
disposed of following applicable federal, state, and
local regulations.
Showers: When there is potential for extensive conta-mination
of the employees’ skin, hair, and protective
clothing, shower facilities must be provided, if feasible,
so that exposed employees can wash lead from their
skin and hair prior to leaving the worksite. Where
showers are provided, employees must change out of
their work clothes and shower before changing into
their street clothes and leaving the worksite.
Workers who do not change into clean clothing before
leaving the worksite may contaminate their homes and
automobiles with lead dust. Other members of the
household may then be exposed to harmful amounts of
lead.
Personal practices ( eating, drinking, etc.): The
employer must ensure that employees who work with
lead either clean or remove their protective clothing and
wash their hands and face prior to eating, drinking,
smoking, or applying cosmetics. These latter practices
are never permitted while in the work area or in areas
subject to the accumulation of lead. HEPA vacuuming
can be used to remove loose contamination from the
work clothing prior to eating.
Washing facilities: Adequate washing facilities must
be provided for employees. Such facilities must be in
near proximity to the worksite and provided with water,
soap, and clean towels to enable employees to remove
lead contamination from their skin.
Contaminated water from washing facilities and
showers must be disposed of in accordance with applica-ble
local, state, or federal regulations.
End- of- day procedures: Workers who are exposed to
lead should follow these procedures upon finishing work
for the day:
18
✦ Place disposable coveralls and shoe covers into
containers designated for lead waste.
✦ Place lead- contaminated clothes, including
work shoes, and personal protective equipment for
laundering/ cleaning ( by the employer) in a closed
container.
✦ Take a shower and wash hair.
✦ Change into street clothes.
19
6
Protective Clothing
At no cost to employees, employers must provide
workers who are exposed to lead above the PEL and for
whom the possibility of skin contamination or skin or
eye irritation exists, clean, dry protective work clothing
and equipment. Appropriate changing facilities must
also be provided. Appropriate protective work clothing
and equipment used on construction sites can include:
• Coveralls or other full- body work clothing
• Gloves
• Vented goggles or face shields with protective
spectacles or goggles
• Welding or blasting helmets, when required
Disposable coveralls and separate shoe covers may be
used, if appropriate, to avoid the need for laundering.
Nondisposable coveralls must be replaced daily. If an
employee leaves the work area wearing protective cloth-ing,
the clothing should be cleaned with high- efficiency
particulate air ( HEPA) filter vacuum equipment to
remove loose particle contamination; or as an alterna-tive,
the coveralls should be removed. Before respirators
are removed, HEPA vacuuming or other suitable method,
such as damp wiping, shall be used to remove loose
particle contamination on the respirator and at the
face- mask seal. Use work garments of appropriate size,
and use duct tape to reinforce their seams ( e. g., under-arm,
crotch, and back).
Contaminated clothing that is to be cleaned, laundered,
or disposed of must be placed in closed containers.
Containers must be labeled with the following warning:
20
Persons responsible for handling contaminated cloth-ing
must be informed of the potential hazard in writing.
At no time should lead be removed from protective cloth-ing
or equipment by any means that disperses lead into
the work area, such as brushing, shaking, or blowing.
At no time should workers be allowed to leave the
worksite wearing lead- contaminated clothing or equip-ment,
( e. g., shoes, coveralls, or head gear). All contami-nated
clothing and equipment must be prevented from
reaching the worker’s home or vehicle. This is an
essential step in reducing the movement of lead
contamination from the workplace into a worker’s
home and provides added protection to employees and
their families.
Gloves and protective clothing should be appropriate
for the specific chemical exposure ( e. g., solvents and
caustics). Cotton gloves provide some protection against
the contamination of hands and cuticles with lead dust.
Workers should wear clothing that is appropriate for
existing weather and temperature conditions under the
protective clothing.
Heat Stress
Workers wearing protective clothing can face a risk
from heat stress. Additionally, heat stress may be an
important concern when working in a hot environment
or within containment structures. Heat stress is caused
by a number of interacting factors, including: environ-mental
conditions, type of protective clothing worn, the
work activity required, and the individual characteris-tics
of the employee.
21
CAUTION: Clothing contaminated with
lead. Do not remove dust by blowing or
shaking. Dispose of lead- contaminated
wash water in accordance with applic-able
local, state, or federal regulations.
In situations where heat stress is a concern,
employers should use appropriate work/ rest regimens
and provide heat stress monitoring that includes
measuring employees’ heart rates, body temperatures,
and weight loss.
A source of water or electrolytic drink should be close
to the work area ( in a noncontaminated eating/ drinking
area) so that it will be used often. Workers should wash
their hands and face prior to drinking any fluid.
Frequent fluid intake throughout the day will replace
body fluids lost to evaporation. If such measures are
used to control heat stress, protective clothing can be
safely worn to provide the needed protection against
lead exposure. The possibility of heat stress and its signs
and symptoms should be discussed with all workers.
22
7
Respiratory Protection
Although engineering and work practice controls are
the primary means of protecting workers, source control
at construction sites is often not sufficient to control
exposure, and airborne lead concentrations may be high
or vary widely. In the construction industry, respirators
must be used at times to supplement engineering
controls and work practices whenever these controls are
technologically incapable of reducing worker exposures
to lead to 50 μg/ m3 or below.
To provide adequate respiratory protection, respira-tors
must be donned before entering the work area and
should not be removed until the worker has left the
area, or as part of a decontamination procedure.
Respiratory Protection Program
When respirators are provided, the employer must
establish a respiratory protection program in
accordance with the OSHA standards on lead in
construction ( interim) respirator protection, 29 CFR
1926.62( f)( 4) and 29 CFR 1910.134. Minimum require-ments
for an acceptable respirator program for lead
include the following elements:
✦ Written standard operating procedures governing
the selection and use of respirators.
✦ Selection of respirators on the basis of hazards to
which the worker is exposed.
✦ Instruction and training in the proper use of respi-rators
and their limitations.
✦ Regular inspection and cleaning, maintenance,
and disinfection. ( Worn or deteriorated parts must
be replaced, including replacement of the filter
23
element in an air- purifying respirator whenever an
increase in breathing resistance is detected.)
✦ Storage in a convenient, clean, and sanitary loca-tion
with protection against sunlight and physical
damage.
✦ Appropriate surveillance of work area conditions
and degree of worker exposure or stress ( physiolog-ical
or psychological) must be maintained.
✦ Evaluation to determine the continued
effectiveness of the program.
✦ Physician’s determination that the employee is
physically able to perform the work and wear a
respirator while performing the work. ( Respirator
user’s medical capacity to wear and work with a
respirator should be reviewed annually.)
✦ Use of Mine Safety and Health Administration/
National Institute for Occupational Safety and
Health ( MSHA/ NIOSH) certified respirators.
✦ Fit testing of negative- pressure respirators.
✦ Breathing air used for supplied- air respirators
must meet the requirements prescribed in 29 CFR
1910.134( b), ( d), ( e), and ( f).
✦ Standing permission for employees to leave the
work area to wash their faces and respirator face
pieces whenever necessary to prevent skin irrita-tion
associated with respirator use.
Respirator Selection
Lead concentrations may vary substantially through-out
a work shift as well as from day to day. The highest
anticipated work concentration is to be used in the initial
selection of an appropriate respirator. The employer
must provide respiratory protection, at no cost to the
employee, and must ensure its proper use in the follow-ing
circumstances:
24
✦ During the time period necessary to install and
implement engineering or work practice controls.
✦ Engineering and work practice controls that can be
instituted are not sufficient to reduce employee
exposure to or below the permissible exposure
limit ( PEL).
✦ Whenever an employee requests a respirator.
An appropriate respirator, which has been approved
by the Mine Safety and Health Administration ( MSHA)
and NIOSH, must be selected to protect against lead
dust, fumes, and mists. ( See Table 2, in this section, for
recommended respiratory protection.)
Respirators issued to employees must exhibit mini-mum
facepiece leakage and fit the employee properly.
Employers must perform either quantitative or qualita-tive
( for half- mask respirators only) face fit tests at the
time of initial fitting and at least every six months for
each employee wearing a negative- pressure respirator.
If the employee shows signs of breathing difficulty dur-ing
the fit test or during use, the employer must make
an examination available in accordance with the med-ical
surveillance requirements of the standard.
Employees who use filter respirators must be permit-ted
to change the filter elements whenever an increase
in breathing resistance is detected. They must be
allowed to leave work areas to wash their faces and res-pirator
facepieces whenever necessary to prevent skin
irritation associated with respirator use.
25
Table 2
Respiratory Protection for Lead Aerosols
26
Not in excess of 2,500 μg/ m3
( 50 X PEL)
Full- facepiece air- purifying respirator with
high- efficiency filters.#
Tight- fitting powered air- purifying respirator
with high- efficiency filters.#
Full- facepiece supplied- air respirator operated
in demand mode.
Half- mask or full- facepiece supplied- air
respirator operated in continuous- flow mode.
Full- facepiece self- contained breathing
apparatus ( SCBA) operated in demand mode.
Greater than 100,000 μg/ m3,
unknown concentration, or
firefighting
Full- facepiece SCBA operated in pressure-demand
or other positive- pressure mode.
Not in excess of 500 μg/ m3
( 10 X PEL)
Half- mask air- purifying respirator with high-efficiency
filters.†#
Half- mask supplied- air respirator operated in
demand ( negative- pressure) mode.
Airborne Concentration of
Lead or Condition of Use Required Respirator*
Not in excess of 1,250 μg/ m3
( 25 X PEL)
Not in excess of 50,000 μg/ m3
( 1,000 X PEL)
Not in excess of 100,000 μg/ m3
( 2,000 X PEL)
Loose fitting hood or helmet powered air-purifying
respirator with high- efficiency filters.#
Hoods or helmet supplied- air respirator
operated in continuous- flow mode— for
example, type CE abrasive blasting respirators
operated in a continuous- flow mode.
Half- mask supplied- air respirator operated in
pressure- demand or other positive- pressure
mode.
Full- facepiece supplied- air respirator
operated in pressure- demand or other
positive- pressure mode— for example,
type CE abrasive blasting respirators
operated in a positive- pressure mode.
Source: “ Lead Exposure in Construction; Interim Final Rule,” Federal Register 58( 84): 26630, May 4, 1993.
* Respirators specified for higher concentrations can be used at lower concentrations of lead.
† Full facepiece is required if the lead aerosols cause eye or skin irritation at the use concentrations.
# A high- efficiency particulate air filter means a filter that is 99.97 percent efficient against particles of 0.3
micron or larger.
If exposure monitoring or experience indicates
airborne exposures to contaminants other than lead,
such as solvents or polyurethane coatings, these expo-sures
must be considered when selecting respiratory
protection. A reevaluation of the respiratory protection
program is required when a worker demonstrates a con-tinued
increase in blood lead levels.
Abrasive Blasting and Related
Operations
NIOSH type CE respirators are required for use by
abrasive blasting operators. Currently, NIOSH certifies
both continuous flow and positive pressure respirators
for abrasive blasting operations. The continuous flow
respirators are recommended by NIOSH only for air-borne
concentrations less than or equal to 25 times 3 the
OSHA PEL of 50 μg/ m3. Positive pressure respirators
are recommended by NIOSH for airborne concentra-tions
less than 2,000 times the OSHA PEL of 50 μg/ m3.
Furthermore, manufacturer’s instructions regarding
quality of air, air pressure, inside diameter of hoses,
and length of hoses must be strictly followed. Use of
longer hoses or smaller inside diameter hoses than the
manufacturer’s specifications or hoses with bends or
kinks may restrict the flow of air to a respirator.
27
________
3Type CE continuous flow respirators used in abrasive blasting that are
manufactured by E. D. Bullard Company ( Models 77 and 88) and CLEMCO
Industries Corporation ( Apollo 20 and Apollo 60) are acceptable in atmos-pheres
where the airborne level does not exceed 50,000 μg/ m3 ( 1,000 times
the PEL) of lead in air. The relief for these two models applies only to lead
in construction. The Assigned Protection Factor ( APF) of 1,000 does not
apply to other air contaminants. Therefore, if silica sand is used as the
blasting agent, the APF reverts back to 25 times the PEL ( 1,250 μg/ m3).
8
Medical Assessment and
Recordkeeping
When a construction employee is occupationally
exposed to lead at or above the action level of 30 μg/ m3
on any one day in a calendar year, the employee must
be provided initial medical surveillance consisting of
biological monitoring in the form of blood sampling and
analysis for lead and zinc protoporphyrin levels. Blood
lead levels are currently the best indicator of personal
lead exposure. Workers potentially exposed to lead at or
above the action level must be monitored for the
presence of lead in the blood and the effects of lead on
the blood- forming system. Full medical surveillance is to
be provided to employees exposed to lead at or above the
action level for more than 30 days per year. All medical
examinations and consultations must be performed by or
under the direct supervision of a qualified physician and
must be provided to employees at no cost, without loss of
pay, and at a reasonable time and place. A qualified
physician is a doctor of medicine ( M. D.) or osteopathy
( D. O.) familiar with the objectives and requirements of a
medical surveillance program for lead exposure.
The following conditions necessitate an immediate
medical consultation including, as determined by the
qualified physician, a physical examination and a blood
sample for lead analysis ( biological monitoring):
• Whenever a worker develops signs or symptoms
associated with lead toxicity.
• Before a worker restarts work following medical
removal.
28
The employer must maintain any employee exposure
and medical records to document ongoing employee
exposure, medical monitoring, and medical removal of
workers. These data provide a base to properly evaluate
the employee’s health. In addition, employees or former
employees, their designated representatives, and OSHA
must be provided access to exposure and medical
records.
Biological Monitoring
The purpose of biological monitoring is to identify
workers with elevated blood lead levels. The data from
biological monitoring are objective evidence of a work-er’s
body burden from lead exposure. These data can be
used to follow changes in worker exposure. Blood lead
and zinc protoporphyrin ( ZPP) or free erythrocyte proto-porphyrin
( FEP) must be monitored for those workers
exposed to lead. In general, workers in high- risk occu-pations
should be monitored as often as needed to pre-vent
adverse health effects.
Reproductive Hazard Issues
Lead is toxic to both male and female reproductive
systems. Workers who are actively seeking to have a
child or who are pregnant should contact qualified med-ical
personnel to arrange for a job evaluation and med-ical
follow- up. Employers who have been contacted by
employees with concerns about reproductive issues
should refer them to qualified medical personnel.
Medical Surveillance
The employer must institute a medical surveillance
program for all employees who are or may be exposed
above the action level for more than 30 days per year.
The employer must maintain an accurate record for
each employee subject to medical surveillance to include
29
a description of the employee’s duties; a copy of the
physician’s written opinions; the results ( as supplied to
the examining physician) of any airborne exposure mon-itoring
done for the representative employee and all
others represented; and any employee medical
complaints related to lead exposure.
The employer must obtain and furnish to the
employee the physician’s written opinion. This opinion
should contain the results of the medical examination
as they relate to occupational exposure to lead and
must include:
• Whether the employee has any detected medical
condition that would place his/ her health at
increased risk from lead exposure.
• Any special protective measures or limitations on
worker’s exposure to lead.
• Any limitation on respirator use.
• Results of blood lead determination.
• A statement that the employee has been informed
by the physician of the results of the consultation
or medical examination and any medical condition
that may require further examination or
treatment.
Findings of lab results or diagnoses unrelated to the
worker’s exposure to lead must not be communicated to
the employer or included in a written opinion. Employees
should be advised by each physician of any medical con-dition,
occupational or nonoccupational, that necessitates
further medical evaluation or treatment. The employer
must furnish the employee with a copy of the written
medical opinion.
In addition, the employer must keep or ensure that
the examining physician keeps the following medical
records: a copy of the medical examination results
30
including medical and work history; a description of the
laboratory procedures and a copy of any guidelines used
to interpret the test results; and a copy of the results of
biological monitoring.
Chelation
The use of chelating drugs as a prophylactic measure
( i. e., to prevent a detectable rise in blood lead) is an
unacceptable medical practice. Chelation may be used
by a qualified physician only for diagnostic or therapeu-tic
reasons ( that is, to diagnose or treat the signs and
symptoms of severe lead toxicity).
Medical Removal
Medical removal will protect worker health both by
stopping further occupational exposure and by enabling
the worker to excrete the absorbed lead naturally. With
good engineering, work practices, personal hygiene, and
respiratory protection practices in place, very few
employees should reach the medical removal trigger
level specified in the OSHA standard. OSHA’s interim
final standard for lead in construction uses a medical
removal trigger level of 50 μg/ dl. However, some author-ities
believe that medical removal should take place at
lower levels.
When employees are removed, or otherwise limited,
they must be placed in jobs that will not result in expo-sure
to lead at or above the action level of 30 μg/ m3. The
employer may return the employee to his or her former
job status when a qualified physician’s medical determi-nation
is that the employee is no longer at risk from
exposure to lead or when the employee’s blood lead level
drops below 40 μg/ dl.
In the case of medical removal, records must include
the following information:
31
• The name and social security number of the worker.
• The date of each occasion that the worker was
removed from current exposure to lead.
• The date on which the worker was returned to his
or her former job status.
• A brief explanation of how each removal was or is
being accomplished.
• A statement indicating whether the reason for the
removal was an elevated blood lead level.
The employer must maintain these records for at
least the duration of any worker’s employment.
Recordkeeping
The employer must establish and maintain an accu-rate
record of all monitoring and other data used to con-duct
employee exposure assessments in accordance with
provisions in 29 CFR 1926.62( n). The following must be
included in exposure monitoring records:
• The dates, number, duration, location, and results
of each sample taken, including a description of
the sampling procedure used to determine repre-sentative
employee exposure.
• A description of the sampling and analytical
methods used and evidence of their accuracy.
• The type of respiratory protection worn, if any.
• The name, social security number, and job classifi-cation
of the monitored employee and all others
whose exposure the measurement represents.
• Environmental variables that could affect the
measurement of employee exposure.
32
Employers must properly record cases on their OSHA
form 200 when the worker:
• Has a blood lead level that exceeds 50 μg/ dl.
• Has symptoms of lead poisoning, such as colic,
nerve damage, renal damage, anemia, or gum
problems.
• Receives medical treatment to lower blood lead
levels or for lead poisoning.
In addition, employees or former employees, their
designated representatives, and OSHNC must be pro-vided
access to exposure and medical records in accor-dance
with 29 CFR 1910.20. When an employer ceases
to do business, the successor employer must receive and
retain all required records.
33
The following industry guides are available from the N. C. Department of Labor’s Division of Occupational
Safety and Health:
1# 1. A Guide to Safety in Confined Spaces
1# 2. A Guide to Procedures of the Safety and Health Review Board of North Carolina
1# 3. A Guide to Machine Safeguarding
1# 4. A Guide to OSHA in North Carolina
1# 5. A Guide for Persons Employed in Cotton Dust Environments
1# 6. A Guide to Lead Exposure in the Construction Industry
1# 7. A Guide to Bloodborne Pathogens in the Workplace
1# 8. A Guide to Voluntary Training and Training Requirements in OSHA Standards
1# 9. A Guide to Ergonomics
# 10. A Guide to Farm Safety and Health
# 11. A Guide to Radio Frequency Hazards With Electric Detonators
# 12. A Guide to Forklift Operator Training
# 13. A Guide to the Safe Storage of Explosive Materials
# 14. A Guide to the OSHA Excavations Standard
# 15. A Guide to Developing and Maintaining an Effective Hearing Conservation Program
# 17. A Guide to Asbestos for Industry
# 18. A Guide to Electrical Safety
# 19. A Guide to Occupational Exposure to Wood, Wood Dust and Combustible Dust Hazards
# 20. A Guide to Crane Safety
# 21. A Guide to School Safety and Health
# 23. A Guide to Working With Electricity
# 25. A Guide to Personal Protective Equipment
# 26. A Guide to Manual Materials Handling and Back Safety
# 27. A Guide to the Control of Hazardous Energy ( Lockout/ Tagout)
# 28. A Guide to Eye Wash and Safety Shower Facilities
# 29. A Guide to Safety and Health in Feed and Grain Mills
# 30. A Guide to Working With Corrosive Substances
# 31. A Guide to Formaldehyde
# 32. A Guide to Fall Prevention in Industry
# 33. A Guide to Office Safety and Health
# 34. A Guide to Safety and Health in the Poultry Industry
# 35. A Guide to Preventing Heat Stress
# 36. A Guide to the Safe Use of Escalators and Elevators
# 37. A Guide to Boilers and Pressure Vessels
# 38. A Guide to Safe Scaffolding
# 39. A Guide to Safety in the Textile Industry
# 40. A Guide to Emergency Action Planning
# 41. A Guide to OSHA for Small Businesses in North Carolina
Occupational Safety and Health ( OSH)
Sources of Information
You may call 1- 800- NC- LABOR ( 1- 800- 625- 2267) to reach any division of the N. C. Department of Labor; or visit the
NCDOL home page on the World Wide Web, Internet Web site address: http:// www. nclabor. com.
N. C. Division of Occupational Safety and Health
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 3rd Floor)
Local Telephone: ( 919) 807- 2900 Fax: ( 919) 807- 2856
For information concerning education, training and interpretations of occupational safety and health standards contact:
Bureau of Education, Training and Technical Assistance
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 4th Floor)
Telephone: ( 919) 807- 2875 Fax: ( 919) 807- 2876
For information concerning occupational safety and health consultative services and safety awards programs contact:
Bureau of Consultative Services
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 3rd Floor)
Telephone: ( 919) 807- 2899 Fax: ( 919) 807- 2902
For information concerning migrant housing inspections and other related activities contact:
Agricultural Safety and Health Bureau
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 2nd Floor)
Telephone: ( 919) 807- 2923 Fax: ( 919) 807- 2924
For information concerning occupational safety and health compliance contact:
Safety and Health Compliance District Offices
Raleigh District Office ( 313 Chapanoke Road, Raleigh, NC 27603)
Telephone: ( 919) 779- 8570 Fax: ( 919) 662- 4709
Asheville District Office ( 204 Charlotte Highway, Suite B, Asheville, NC 28803- 8681)
Telephone: ( 828) 299- 8232 Fax: ( 828) 299- 8266
Charlotte District Office ( 901 Blairhill Road, Suite 200, Charlotte, NC 28217- 1578)
Telephone: ( 704) 665- 4341 Fax: ( 704) 665- 4342
Winston- Salem District Office ( 4964 University Parkway, Suite 202, Winston- Salem, NC 27106- 2800)
Telephone: ( 336) 776- 4420 Fax: ( 336) 776- 4422
Wilmington District Office ( 1200 N. 23rd St., Suite 205, Wilmington, NC 28405- 1824)
Telephone: ( 910) 251- 2678 Fax: ( 910) 251- 2654
*** To make an OSHA Complaint, OSH Complaint Desk: ( 919) 807- 2796***
For statistical information concerning program activities contact:
Planning, Statistics and Information Management
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 2nd Floor)
Telephone: ( 919) 807- 2950 Fax: ( 919) 807- 2951
For information about books, periodicals, vertical files, videos, films, audio/ slide sets and computer databases contact:
N. C. Department of Labor Library
Mailing Address: Physical Location:
1101 Mail Service Center 111 Hillsborough St.
Raleigh, NC 27699- 1101 ( Old Revenue Building, 5th Floor)
Telephone: ( 919) 807- 2848 Fax: ( 919) 807- 2849
N. C. Department of Labor ( Other than OSH)
1101 Mail Service Center
Raleigh, NC 27699- 1101
Telephone: ( 919) 733- 7166 Fax: ( 919) 733- 6197